ML20041F140
| ML20041F140 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 03/11/1982 |
| From: | Kemper J PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | Haynes R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| References | |
| NUDOCS 8203160227 | |
| Download: ML20041F140 (5) | |
Text
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PHILADELPHIA ELECTRIC COMPANY 23O1 M AR'KET STREkT P.O. BOX 8699
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JOHN S. KEMPER j,
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p Mr. Ronald C. Haynes, Dirhetor f]g*y O ISO 2sai. g
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United States Euclear Regulatory Commission Cg Office of Inspection and Enforcement Begion I E,
631-Park Avenue e
Eing of Prussia, PA 19h06
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Fubjoot URUtC IE Region Letter dated February 9,
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RE: Inspection of January 11-29, 1982 Inspection Report 30. 50-352/62-03&50-353/62-02 Lincrick Generating Station - Unite 1 and 2 Filos QUAL 1-2-2 (352/82-03&353/82-02)
Dear Mr. Haynes In responno to the oubject letter regarding itoma identified during the subject inspootion of construction activities authorized by URC License Nos. CPPb1C6 and -107, we transmit herewith the
.'ollovirg:
Attach:r.ent I - Hesponse to Appendix A Also enclosed as required by the Notice of Violation, is an affidavit relating to the res,once.
'Should you.have any questions concerning these items, wo would be pleased to dincuan them with you.
Sincorely, Attachment Copy to Director of Inspection and Ihforcement United States Euclear Regulatory Cocaission Vashington, D.C.
20555 J. P. Iurr,' USNRC Hosident Inspector
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8203160227 820311 PDR ADOCK 05000352 l
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ATTACHMENT I RESPONSE TO APPENDIX A VTOLATION A
10CFR 50.55a requires that Class 1 valves comply with the ASME Draft Code for Pumps and Valves (DCPV), which specifies in Section 314.1.6 that repair welding procedures be qualified in accordance with ASME Code Section IX.
ASME Cede Section IX, Paragraph V-6 requires welding procedure requalification if there is a change.in the heat treating temperature.
The repair welding procedure, QAP-49D, dated May 7, 1971, and Procedure Qualification Record QAP-49D, dated October 26, 1971, limit post-weld heat treatment temperatures to 1100 degree-1300 degree (Fahrenheit).
Further, DCPV.Section 314 specifies that nondestructive tests must be performed after any heat treatment.
Contrary to the above, from December 20, 1971 to February 12, 1972, Class 1 Main Steam Isolation Valve B21F022D, Serial No.
3-683, was repair welded, radiographed, and post-weld heat t rea ted / tempe red at 1%0 degree F.
RESPONSE TO VIOLATION The response'to this violation is addressed in two s,eparate parts:
1.
Radiography Before Tempering:
The valve supplier's and licensee's interpretation of the code requirement for the timing of radiography is:
The March 1970 Addendum of the Draft Pump and Valve Code allows radiog-raphy to be performed at any time.
Paragraph 615.3(b) states:
" Radiographic, ultrasonic and eddy current' examinations may be performed before or after any forming or heat treatment."
- Also, Section 314 of the 1968 Draft'ASME Code for Pumps and Valves for Nuclear Power requires that "non-destructive examinations for materials shall be performed after any heat treatments required by the Material Specification".
The Material Specification for the MSIV's (ASTM A216-69) requires that'the materials be-either normalized or normalized and tempered.
Thus, the Draft Pump and Valve Code is interpreted for ASTM A216-69 to mean:
"non-destructive examinations for materials shall be performed after normalizing or normalizing and tempering."
This interpretation is considered as good engineering practice because tempering would not cause any change or growth of indications or defects.
I 1/3 352/82-03 353/82-02
i.
The March 1970 Addenda was issued to make editorial and other essen'tial. changes to the November 1968 draft of the ASME. Code-for Pumps and Valves for Nuclear Power and was invoked in the purchase order to the valve body manufacturer.
Philadelphia Elcetric intends to note the use of this Addenda in the FSAR.
This interpretation is consistent with current editions of Section III of the ASME B&PV Code which allows radiography to be
-performed 12 any heat treated condition and does not state:
."after material properties are established".
2.
Post Weld Heat Treatment.At 1340 degree F:
Weld Procedure 1QAP-49D, dated May 7, 1971 was used for repair welds on MSIV B22F022D.
However, in March of 1973, Phila-delphia Electric Company identified a noncompliance to this procedure during a source audit:
weld repairs'in excess of the qualified size range were made.
Corrective action to this finding
-was to modify,the procedure.
Previous to this finding, a qualification of this procedure was per' formed and a PQR existed for the larger welds.
The modified procedure was back dated October 26, 1971 to match the date of the PQR.
The October 26,.
1971 procedure was submitted as part of the final documentations package for the valve and therefore this was the procedure used in reviewing the final records.
QAP-49D dated October 26, 1971 did not limit post weld heat treatment temperatures.
In addition, the DCPV did not limit the temperatures as do more current editions'of the Code.
(Section III started in 1973 to limit PWHT temperatures to 1250-degree F for carbon steel).
Also, Section,IX of the Code was ambiguous in regard to what change in heat treatment temperatures constituted the need for procedure requalification.
However, recent' editions of Section IX have cleared the ambiguity.
In view of the current interpretation, we-a:c in the process of qualifying the weld procedure for the post weld heat treatment temperatures used.
We expect to have the quallfleation tests completed and evaluated by May 31, 1982.
We have reviewed the documentation of several other items supplied by the same foundry and samples of other suppliers and have determined that the high post weld heat treatment temperatures are isolated to the MSIV's.
Also, since 1973 the Code has limited post weld heat treatment temperatures.
Therefore, other than the above described actions, no additional action to prevent recurrence is needed.
I i
I 2/3 352/82 353/82-02 m_.-
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l Violation - B
-l 10CFR 50 Appendix B Criterion V requires that activities affecting quality be performed in accordance with procedures.
I Project Special Provision-Notice PSP G-6.1,.Revison 3, Paragraph 3.1.5, specifies that-inspection hold points are mandatory and work shall not proceed.to a point where work is no longer inspectable.
Quality Control Instruction-W-2.00, Paragraph 2.4.a.1, requires that minimum preheat and interpass temperatures be verified for full penetration groove welds as.a hold point inspection.
Contrary to the above, reviews on January 21, 1982, disclosed l
that the preheat and interpass temperature hold point inspections for full penetration groove welds listed on Quality Control Inspection Record C-1415-W-1 had not been performed, and the welds had been completed without them.
Response to Violation Bechtel Power Corporation NCR 5353 was written reporting t% t the preheat had not been verified on Quality Control Inspection Record C-1415-W-1.
The NCR has been dispositioned by Bechtel design engineers to "use-as-is".
The rationale for this decision is that the preheat requirements for these welds are to preheat to 70 degree F if the ambient temperature is below 32 degree F.
The subject welds were performed during May and June of 1979, when the ambient.
temperature was above 32 degree F.
The subject Quality Control Inspection Record C-1415-W-1 did not require interpass temperature inspection.
In an effort to determine if this Inspector had missed other preheat hold point inspections, twelve (12) other inspection records com-pleted by him were reviewed for similar discrepancies.
No other discrepancies or missing sign-offs were found on these records.
All open Civil Quality Control Inspection Records were reviewed for.
preheat requirements and' sign-offs. 'All were found in conformance with the applicable procedures.
A training session was held on January 13, 1982 for Quality Control Welding Incpectors emphasizing the proper preheat requirements.
I 3/3 352/82-03 353/82-02 O
, u COMMONWEALTH OF PENNSYLVANIA :
as.
COUNTY OF PHILAI)ELPHIA JOHN S. KEMPER, being first duly sworn deposes and says:
That he is Vice President of Philadelphia Electric Company, the holder of Construction Permits CPPR-106 and j
CPPR-107 for Limerick Generating Station Unita 1 and 2; that he has read the foregoing Response to Inspection Report No. 50-352/82-03 and 50--353/82-02 and knows the contento thoroof; and that the statements and matters set forth therein are true and correct to the best of hic knowledge, infonnation and belief.
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f Subscribed and sworn to before me this I t'" day or N o c a, l'10:4.
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